POS 02 vs POS 10 and Modifier 95: Telehealth Billing Rules for 2026

Use POS 10 when the patient is at home during the telehealth visit and POS 02 when the patient is anywhere else. Medicare pays POS 10 at the higher non-facility rate and POS 02 at the lower facility rate. On most Medicare professional claims the POS code is what marks the visit as telehealth, so modifier 95 is only needed in a few set cases, while many Medicaid and commercial plans, including Texas plans, still require it.

That one difference between Medicare and every other payer is where most telehealth billing confusion in 2026 comes from. This guide explains the current rules after Congress extended Medicare telehealth through December 31, 2027, shows exactly when to use POS 02, POS 10 and modifier 95, and lists the mistakes that turn into denials. It was checked against the CMS Telehealth FAQ updated in October 2026 and the CY 2026 Physician Fee Schedule final rule.

Telehealth Billing in 2026 at a Glance

• POS 10: telehealth provided while the patient is in their home. Medicare pays the non-facility rate.
• POS 02: telehealth provided while the patient is somewhere other than home, such as a clinic or hospital. Medicare pays the facility rate.
• Modifier 95: real-time audio and video. Medicare needs it only in specific cases. Many Medicaid and commercial plans require it on every video visit.
• Modifier 93: audio-only visit. RHCs and FQHCs may use FQ instead.
• Coverage window: Medicare telehealth flexibilities run through December 31, 2027 under the Consolidated Appropriations Act, 2026.
• Next change: CMS says new BB and BC modifiers start January 1, 2027, and an in-person rule for mental health telehealth returns after 2027.

What Changed in Telehealth Billing for 2026

The biggest change in 2026 was not a new code. It was a near miss. Medicare telehealth flexibilities lapsed during the fall 2025 government shutdown and again for a few days after January 30, 2026. On February 3, 2026, the Consolidated Appropriations Act, 2026 extended them through December 31, 2027. CMS confirms in its telehealth FAQ that the flexibilities apply retroactively, as if no lapse happened, so claims from those gaps are paid under the normal rules.

Under the extension, through the end of 2027:

• Patients can receive Medicare telehealth anywhere in the United States, including at home, with no rural or geographic limit.
• Audio-only telehealth is still allowed when the patient is at home.
• The expanded list of practitioners, including physical therapists, occupational therapists, speech-language pathologists and audiologists, can keep billing telehealth.
• The in-person visit requirement for mental health telehealth stays on hold until after December 31, 2027.
• RHCs and FQHCs can keep billing non-behavioral telehealth visits.

The CY 2026 Physician Fee Schedule final rule added a few permanent changes on top of that:

• Virtual direct supervision is permanent. Direct supervision can be met through real-time audio and video, but not audio-only. Services with a 010 or 090 global period are excluded.
• Frequency limits are gone for subsequent inpatient visits, subsequent nursing facility visits and critical care consultations.
• A simpler telehealth list. CMS dropped the provisional and permanent labels on the Medicare telehealth services list and added services such as group behavioral counseling for obesity.
• Originating site fee. HCPCS Q3014 pays 80% of the lesser of the actual charge or $31.85 in 2026.

Important: RHCs and FQHCs had a coding change mid-year. Through September 30, 2026 they reported non-behavioral telehealth with HCPCS G2025. From October 1, 2026, CMS asks them to bill the actual CPT or HCPCS code with the telehealth modifier instead of G2025. Claims still using G2025 after that date are at risk of rejection.

POS 02 vs POS 10: The Difference

Both codes come from the CMS place of service code set, and both tell the payer the service was delivered through telecommunication technology. The only question that separates them is where the patient was during the visit. Where the provider sat does not matter for the POS code.

POS code	Patient location	Medicare payment rate	Typical example
POS 10	In their own home	Non-facility rate	Video follow-up with a patient sitting in their living room
POS 02	Anywhere other than home	Facility rate	Patient at a rural clinic, hospital, nursing facility, school or workplace
POS 11	In the office, in person	Non-facility rate	Not a telehealth code for Medicare in 2026

Before 2024, Medicare told practices to bill telehealth with the POS that would have applied in person, usually POS 11, plus modifier 95. That instruction ended on December 31, 2023. Some billing systems and some staff still follow it, which is why POS 11 with modifier 95 still shows up on Medicare claims and gets paid wrong or denied.

Tip: Ask the patient where they are at the start of every visit and record it in the note. A patient who logs in from their car or office is POS 02, not POS 10, even though they are not in a clinic.

Why the POS Code Changes What You Get Paid

Medicare pays two rates for most physician services. The non-facility rate includes the practice expense of running an office, such as staff, space and equipment. The facility rate is lower because it assumes a hospital or other facility is carrying those costs.

Since January 1, 2024, Medicare pays telehealth billed with POS 10 at the non-facility rate, the same as an office visit. Telehealth billed with POS 02 is paid at the facility rate. So a practice that bills every telehealth visit as POS 02 out of habit is quietly underpaying itself on every visit where the patient was actually at home.

The reverse also carries risk. Billing POS 10 when the patient was in a clinic overstates payment and can come back as an overpayment in an audit. The fix for both is the same: bill what the documentation shows.

Modifier 95: What It Means and When It Is Required

Modifier 95 means a synchronous telemedicine service delivered through a real-time interactive audio and video system. It describes how the visit happened. It does not change the Medicare payment amount; for Medicare, the POS code does that.

Medicare: only in specific cases

Medicare contractors say modifier 95 is not required on ordinary professional telehealth claims billed with POS 02 or POS 10. Noridian limits it to visits where the clinician is in a hospital and the patient is at home, and to outpatient therapy by a PT, OT or SLP. First Coast lists the same uses plus:

• Physician telehealth for Acute Hospital Care at Home patients, billed with POS 21 and modifier 95.
• Hospital outpatient therapy furnished by hospital-employed PT, OT and SLP staff on institutional claims.
• Opioid treatment program services furnished through audio and video.

Adding modifier 95 to a Medicare claim that does not need it is usually harmless, but it should be a deliberate rule in your billing system, not a leftover from the public health emergency.

Medicaid and commercial plans: often required

Outside Medicare, modifier 95 is still common and often mandatory. For example, Aetna’s Texas telemedicine policy asks providers to bill POS 02 and/or modifier 95 for real-time audio and video, and uses modifier GT for store and forward, a different meaning from Medicare. Many Medicaid programs and Medicare Advantage plans have their own versions of these rules, and some still want the in-person POS with modifier 95.

Other Telehealth Modifiers: 93, FQ, GT, GQ and G0

Modifier 95 gets most of the attention, but five other modifiers show up on telehealth claims. Using the wrong one is a common cause of CO 4 denials.

Modifier	Meaning	When to use it
95	Synchronous audio and video	Payer requires it, or one of the Medicare cases above
93	Synchronous audio only	Patient at home cannot use video or does not consent to it
FQ	Audio only, RHC or FQHC	Rural health clinic or FQHC audio-only visit (93 is also accepted)
GT	Interactive audio and video	Medicare: CAH Method II institutional claims only. Some commercial plans use it differently.
GQ	Asynchronous store and forward	Medicare federal telemedicine demonstration in Alaska or Hawaii
G0	Acute stroke telehealth	Diagnosis, evaluation or treatment of an acute stroke

Note: CPT also marks codes that can be done through audio and video with a star symbol, and a separate CPT appendix lists audio-only codes. Medicare coverage still depends on the CMS telehealth list, not the CPT symbol.

POS and Modifier Rules by Payer Type

This is the table to keep next to your claim scrubber. The Medicare column is fixed by CMS. The other columns are typical patterns, so the payer’s written telehealth policy always wins.

Payer type	Telehealth POS	Modifier 95	Audio-only
Original Medicare	POS 10 at home, POS 02 elsewhere	Only in set cases (hospital clinician, therapy, hospital at home, OTP)	Allowed at home through 2027 with modifier 93
Medicare Advantage	Usually follows Medicare, but plan rules apply	Check the plan policy	Varies by plan
Medicaid, including Texas Medicaid	Set by each state and managed care plan	Often required	Often covered for set services only
Commercial plans	Often POS 02, sometimes POS 10 or the in-person POS	Often required on video visits	Frequently limited or not covered

Texas law already prevents health plans from requiring a face-to-face visit before covering telemedicine, but each plan still decides how the claim must be coded. Build payer specific rules into your system instead of one telehealth rule for everyone.

Telehealth Billing Examples

Example: A Medicare patient joins a video follow-up from home and the physician bills 99214. Use POS 10. No modifier 95 is needed for Medicare. Payment is at the non-facility rate.

Example: A Medicare patient sits in a rural clinic while a specialist sees them by video from another city. The specialist bills the visit with POS 02 and is paid at the facility rate. The clinic, as the originating site, can bill HCPCS Q3014.

Example: A Medicare patient with depression is at home and has no working camera, so the therapist completes the session by phone. Use POS 10 with modifier 93 and document why video was not used.

Example: A Texas patient covered by a commercial plan has a video visit from home. Follow that plan’s telehealth policy. Under Aetna’s Texas policy, for instance, the claim needs POS 02 and/or modifier 95 rather than the Medicare style POS 10 with no modifier.

Common Telehealth Billing Mistakes and Denials

Most telehealth denials come from a small set of repeat errors. The remittance advice usually points straight at the cause.

Mistake	What happens	Likely denial or result
POS 11 with modifier 95 on a 2026 Medicare claim	Old public health emergency rule still in the system	Paid at the wrong rate or denied for place of service
POS 02 when the patient was at home	Claim is paid at the lower facility rate	Silent underpayment, no denial
Missing modifier 95 for a commercial or Medicaid plan	Plan cannot confirm the visit was video	CO 4, required modifier missing
Service not on the payer’s telehealth list	Code is not approved for telehealth	CO 5 or CARC 58, invalid place of service
Audio-only visit without modifier 93 or FQ	Billed as if it were video	Denial or recoupment after audit
Note does not show patient location or modality	Claim cannot be defended on review	Recoupment in a post payment audit

If one of these is already hitting your remittances, our guides to the CO 16 denial code and medical billing denial management walk through the correction and appeal steps.

Telehealth Documentation Checklist

Good telehealth billing starts in the visit note. Every telehealth note should show:

1. Where the patient was during the visit, such as home, work or a named clinic.
2. Where the provider was during the visit.
3. Whether the visit used audio and video or audio only, and why audio-only was used if it was.
4. The patient’s consent to receive care through telehealth.
5. Start and end time, or total time when the code is time based.
6. The same clinical detail you would record for an in-person visit to support the level of service.

Key takeaway: On Medicare claims the patient’s location picks the POS code and the POS code sets the payment. On every other payer’s claims, read the plan policy before you decide on POS 02, POS 10 or modifier 95.

What Is Coming in 2027 and 2028

Practices should plan now for two dates:

• January 1, 2027: CMS says new BB and BC modifiers will be required on certain telehealth claims tied to how the billing practitioner is contracted. CMS states they will not change payment. Watch the CY 2027 Physician Fee Schedule final rule for the exact definitions.
• January 1, 2028: unless Congress acts again, the in-person visit within 6 months before mental health telehealth returns, home telehealth for non-behavioral services ends for most patients and audio-only is limited to behavioral health.

Patients who started home mental health telehealth on or before December 31, 2027 are treated as established, but CMS says they will still need an in-person visit at least every 12 months after that date.

How ZanexMed Helps With Telehealth Billing

ZanexMed sets payer specific telehealth rules in your claim workflow, so POS 02, POS 10 and modifier 95 are applied the way each payer expects. Our team reviews telehealth denials and underpayments, corrects and resubmits claims, and appeals when the record supports it. See our medical coding services and denial management services, or request a free billing audit.

Telehealth Billing FAQs

Sources

• CMS, Telehealth FAQ, updated October 2026
• CMS, MLN MM14315: CY 2026 Physician Fee Schedule final rule summary
• CMS, Place of Service code set
• CMS, List of Medicare telehealth services
• Noridian Medicare, Telehealth
• First Coast Service Options, Telehealth service modifiers
• Aetna, Texas telemedicine policy
• NASW, Congress passes two-year extension of Medicare telehealth flexibilities

This guide is for general billing education and reflects rules in effect on November 3, 2026. It is not legal advice. Confirm payer specific rules before submitting claims.